Privacy Policy and Data Protection

1.  INTRODUCTION

This privacy notice, together with our website terms of use and any other documents referred to in it, provides you with details of how we collect and process your personal data through your use of our sites  

mutusystem.com/en-uk/

mutusystem.com/en-us/ 

mutumamas.com

including any information you may provide through our site when you purchase a product or service, subscribe to the MUTU System web application, sign up to our newsletter or take part in a prize draw or competition.

Planet Mutu Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Planet Mutu Limited

Email address: [email protected]

Postal address: Office 1, The Warehouse, Anchor Quay, Penryn TR10 8GZ

Data Protection Officer

Outsourced DPO services provided by: NaqCyber

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected].

By providing us with your data, you warrant to us that you are over 13 years of age. If you do become aware of a user who is 13 years of age or under and who potentially does not have parental consent then you need to contact us at [email protected].

2.  WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

• Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• *Special Category Data such as health, sex life/sexual orientation, and ethnicity when you subscribe to MUTU System.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

*Sensitive/Special Category Data

Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We do not collect any information about criminal convictions and offences.

We collect the following sensitive data about you in order to define certain types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy.

The sensitive data we collect is mainly health data but we may also collect sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation and political opinions, when you subscribe to MUTU System.

We rely on your  explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

Data Minimisation

We only collect personal data that is necessary for the purposes for which it was collected. This includes on our MUTU System website application where we only process the minimum amount of personal data necessary to subscribe to the app.

3.  HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our site (or otherwise), subscribing to MUTU System, or by communicating with us by post, phone, email or otherwise, including when you:

• order our products or services;
• create an account on our site;
• interact in our ‘members only‘ forum ‘Connect’
• subscribe to our service or publications;
• request resources or marketing be sent to you;
• enter a competition, prize draw, promotion or survey; or
• give us feedback.

Automated technologies or interactions: As you use our site and our web application, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at https://mutusystem.com/privacy-cookie-policy for further details.:

Technical Data from the following parties:

• analytics providers such as Google based outside the UK and the EU;
• advertising networks such as Facebook Ads and Google Ads based outside of the UK and the EU;
• search information providers such as Google based outside the UK and the EU;
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the UK and the EU;
• Identity and Contact Data from publicly available sources such as Royal Mail and the Electoral Register based inside the UK and the EU.

4.  HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• When you have consented to us processing your personal data such as when you subscribe to MUTU System.

We will also rely on consent as a legal ground for processing your personal data in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at [email protected].

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at [email protected] if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

You have the right to opt out of some of this processing (see ‘Data Subject Rights’ section below) where we are relying on consent or legitimate interests. You can not opt out of processing if we are relying on ‘performance of a contract’ or where we are legally obliged to process your personal data. You can contact us at [email protected] at any time if you have any questions or wish to exercise your rights.

Marketing communications

You will receive marketing communications from us if you have consented or we are relying on the ‘soft opt in’ to communicate with you:

1. requested information from us or purchased goods or services from us;
2. when you have subscribed to MUTU System; or
3. if you provided us with your details when you entered a competition or registered for a promotion or free resources; and
4. in each case, you have consented to receiving that marketing.

We will get your consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time

1. i) by following the opt-out links on any marketing message sent to you OR
2. ii) by emailing us at [email protected] at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at [email protected].

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Service providers who provide IT and system administration services.
• Fulfilment providers who process kitbag orders
• Processors who process personal data on our behalf for the purposes of managing subscribers to MUTU System
• Professional advisers, business partners, suppliers and subcontractors including lawyers, bankers, auditors and insurers and other consultants who provide services such as consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

6.  DATA STORAGE AND INTERNATIONAL TRANSFERS

Countries outside of the UK and the EU/European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so transfers of personal data outside of the UK are prohibited unless the transfer meets certain criteria.

Many of our third party service providers are based outside the UK and the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and the EEA.

Whenever we transfer your personal data out of the UK and the EEA, we ensure a similar degree of security of data by implementing one of the following safeguards:

• We will only transfer your personal data to countries or frameworks that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission; or
• Where we use certain service providers, we may use specific contracts approved by the UK Government or by the European Commission (with the UK Addendum) which give personal data the same protection it has in UK and Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the Data Privacy Framework which requires them to provide similar protection to personal data shared between the UK and/or the EU and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

If you are a subscriber to MUTU system your personal data will be processed and held in servers in the United States. We have in place safeguards including a Data Processing Addendum and data processing contractual clauses to ensure that your personal data is protected to an equivalent standard to the UK.

Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7.  DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place appropriate security measures to protect personal data within the MUTU System website application.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

If you are a subscriber to MUTU System we will retain your personal data while you are a subscriber and will then delete it manually in line with our retention policy or if you request erasure of your personal data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  DATA SUBJECT RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent
• Right not to be subject to decisions based solely on automated processing/profiling.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected].

We do not currently base decisions on automated processing or profiling which produces a legal effect or significantly affects you. However, if we do we will tell you and you will have the right to ask us not to be subject to an automated decision based solely on automated processing, including profiling, which produces legal effect concerning you or significantly affects you.

You will in most cases not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy here.

12 CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Notice in the future will be posted on this page and, where appropriate , notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.

Privacy Notice last updated November 2023.